Wikipedia

Santa Susana Field Laboratory

(Redirected from Rocketdyne Santa Susana Field Laboratory Contamination)

The Santa Susana Field Laboratory (SSFL), formerly known as Rocketdyne, is a complex of industrial research and development facilities located on a 2,668-acre (1,080 ha)[1] portion of Southern California in an unincorporated area of Ventura County in the Simi Hills between Simi Valley and Los Angeles. The site is located approximately 18 miles (29 km) northwest of Hollywood and approximately 30 miles (48 km) northwest of Downtown Los Angeles. Sage Ranch Park is adjacent on part of the northern boundary and the community of Bell Canyon is along the entire southern boundary.[2]

Aerial view of the Santa Susana Field Laboratory in the Simi Hills, with the San Fernando Valley and San Gabriel Mountains beyond to the east. The Energy Technology Engineering Center site is in the flat Area IV at the lower left, with the Rocket Test Field Laboratory sites in the hills at the center. (Spring 2005)

SSFL was used mainly for the development and testing of liquid-propellant rocket engines for the United States space program from 1949 to 2006,[1] nuclear reactors from 1953 to 1980 and the operation of a U.S. government-sponsored liquid metals research center from 1966 to 1998.[3] Throughout the years, about ten low-power nuclear reactors operated at SSFL, (including the Sodium Reactor Experiment, the first reactor in the United States to generate electrical power for a commercial grid, and the first commercial power plant in the world to experience a partial core meltdown) in addition to several "critical facilities" that helped develop nuclear science and applications. At least four of the ten nuclear reactors had accidents during their operation. The reactors located on the grounds of SSFL were considered experimental, and therefore had no containment structures.

The site ceased research and development operations in 2006. The years of rocket testing, nuclear reactor testing, and liquid metal research have left the site "significantly contaminated". Environmental cleanup is ongoing. The public who live near the site have strongly urged a thorough cleanup of the site, citing cases of long term illnesses, including cancer cases at rates they claim are higher than normal. Experts have said that there is insufficient evidence to identify an explicit link between cancer rates and radioactive contamination in the area.[4]

Introduction

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Santa Susana Field Laboratory administrative areas, and the surrounding communities

Since 1947 the Santa Susana Field Laboratory location has been used by a number of companies and agencies. The first was Rocketdyne, originally a division of North American Aviation (NAA), which developed a variety of pioneering, successful, and reliable liquid rocket engines.[5] Some were used in the Navaho cruise missile, the Redstone rocket, the Thor and Jupiter ballistic missiles, early versions of the Delta and Atlas rockets, the Saturn rocket family, and the Space Shuttle Main Engine.[6] The Atomics International division of North American Aviation used a separate and dedicated portion of the Santa Susana Field Laboratory to build and operate the first commercial nuclear power plant in the United States,[7] as well as for the testing and development of compact nuclear reactors, including the first and only known nuclear reactor launched into Low Earth Orbit by the United States, the SNAP-10A.[8] Atomics International also operated the Energy Technology Engineering Center for the U.S. Department of Energy at the site. The Santa Susana Field Laboratory includes sites identified as historic by the American Institute of Aeronautics and Astronautics and by the American Nuclear Society. In 1996, The Boeing Company became the primary owner and operator of the Santa Susana Field Laboratory and later closed the site.

Three California state agencies (Department of Toxic Substances Control, Department of Public Health Radiologic Health Branch, and the Los Angeles Regional Water Quality Control Board) and three federal agencies (Department of Energy, NASA, and EPA) have been overseeing a detailed investigation of environmental impacts from historical site operations since at least 1990. Concerns about the environmental impact of past nuclear energy and rocket test operations, and waste disposal practices, have inspired several lawsuits seeking payments from Boeing.  Litigation and legislation have also attempted to change established remediation and decommissioning processes.  Several interest groups (Committee to Bridge the Gap, Natural Resource Defense Council, Physicians for Social Responsibility - Los Angeles) and numerous others, are actively involved with steering the ongoing environmental investigation.[9][10]

The Santa Susana Field Laboratory is the focus of diverse interests. Burro Flats Painted Cave, listed on the National Register of Historic Places, is located within the Santa Susana Field Laboratory boundaries, on a portion of the site owned by the U.S. government.[11] The drawings within the cave have been termed "the best preserved Indian pictograph in Southern California." Several tributary streams to the Los Angeles River have headwater watersheds on the SSFL property, including Bell Creek (90% of SSFL drainage), Dayton Creek, Woolsey Canyon, and Runkle Creek.[12]

History

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Aerial view looking north, of the Energy Technology Engineering Center in Area IV (1990)

SSFL was a United States government facility dedicated to the development and testing of nuclear reactors, powerful rockets such as the Delta II, and the systems that powered the Apollo missions. The location of SSFL was chosen in 1947 for its remoteness in order to conduct work that was considered too dangerous and too noisy to be performed in more densely populated areas. In subsequent years, the Southern California population grew, along with housing developments surrounding the area.

The site is divided into four production and two buffer areas (Area I, II, III, and IV, and the northern and southern buffer zones). Areas I through III were used for rocket testing, missile testing, and munitions development. Area IV was used primarily for nuclear reactor experimentation and development. Laser research for the Strategic Defense Initiative (popularly known as "Star Wars") was also conducted in Area IV.[13]

Rocket engine development

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Research, development and testing of rocket engines was conducted on a regular basis in Area II of the SSFL from the mid 1950s through the early 1980s. These activities were conducted by the U.S. Army, Air Force, and NASA. Subsequently, occasional testing took place until 2006.[14]

North American Aviation (NAA) began its development of liquid propellant rocket engines after the end of WWII. The Rocketdyne division of NAA, which came into being under its own name in the mid-1950s,[citation needed] designed and tested several rocket engines at the facility. They included engines for the Army's Redstone (an advanced short-range version of the German V-2), and the Army Jupiter intermediate range ballistic missile (IRBM) as well as the Air Force's counterpart IRBM, the Thor.[citation needed] Also included among those developed there, were engines for the Atlas Intercontinental Ballistic Missile (ICBM), as well as the twin combustion chamber alcohol/liquid oxygen booster engine for the Navaho, a large, intercontinental cruise missile that never became operational. Later, Rocketdyne designed and tested the J-2 liquid oxygen/hydrogen engine which was used on the second and third stages of the Saturn V launch rocket developed for the moon-bound Project Apollo mission. While the J-2 was tested at the facility, Rocketdyne's huge F-1 engine for the first stage of the Saturn V was tested in the Mojave desert near Edwards Air Force Base. This was due to safety and noise considerations, since SSFL was too close to populated areas.[15]

NASA conducted Space shuttle main engine tests at SSFL from 1974 to 1988.[14]

Nuclear and energy research and development

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Main article: Atomics International
 
SSFL: the Atomics International Snap reactor

The Atomics International Division of North American Aviation used SSFL Area IV as the site of United States first commercial nuclear power plant [16] and the testing and development of the SNAP-10A, the first nuclear reactor launched into outer space by the United States.[17] Atomics International also operated the Energy Technology Engineering Center at the site for the U.S. government. As overall interest in nuclear power declined, Atomics International made a transition to non-nuclear energy-related projects, such as coal gasification, and gradually, ceased designing and testing nuclear reactors. Atomics International eventually was merged with the Rocketdyne division in 1978.[18]

Sodium reactor experiment

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Main article: Sodium Reactor Experiment

The Sodium Reactor Experiment (SRE) was an experimental nuclear reactor that operated at the site from 1957 to 1964 and was the first commercial power plant in the world to experience a core meltdown.[19] There was a decades-long cover-up of the incident by the U.S. Department of Energy.[20] The operation predated environmental regulation, so early disposal techniques are not recorded in detail.[20] Thousands of pounds of sodium coolant from the time of the meltdown are not yet accounted for.[21][22]

The reactor and support systems were removed in 1981 and the building torn down in 1999.[23]

The 1959 sodium reactor incident was chronicled on History Channel's program Engineering Disasters 19.

In August 2009, on the 50th anniversary of the SRE accident, the Department of Energy hosted a day-long public workshop for the community, employees, and retirees.  The workshop featured three experts – Dr. Paul Pickard of DOE's Sandia National Laboratories, Dr. Thomas Cochran of the Natural Resources Defense Council, and Dr. Richard Denning of Ohio State University – as well as a Q&A and discussion. All three experts agreed that there was not significant public harm from the release of radioactive noble gases, but held conflicting views about the amounts and health harms of other radioactive fission products potentially released.[24]

Energy Technology Engineering Center

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Main article: Energy Technology Engineering Center

The Energy Technology Engineering Center (ETEC), was a government-owned, contractor-operated complex of industrial facilities located within Area IV of the Santa Susana Field Laboratory. The ETEC specialized in non-nuclear testing of components which were designed to transfer heat from a nuclear reactor using liquid metals instead of water or gas. The center operated from 1966 to 1998.[25] The ETEC site has been closed and is now[needs update] undergoing building removal and environmental remediation by the U.S. Department of Energy.[citation needed]

Accidents and site contamination

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Nuclear reactors

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Throughout the years, approximately ten low-power nuclear reactors operated at SSFL, in addition to several "critical facilities": a sodium burn pit in which sodium-coated objects were burned in an open pit; a plutonium fuel fabrication facility; a uranium carbide fuel fabrication facility; and the purportedly largest "Hot Lab" facility in the United States at the time.[26] (A hot lab is a facility used for remotely handling or machining radioactive material.) Irradiated nuclear fuel from other Atomic Energy Commission (AEC) and Department of Energy (DOE) facilities from around the country was shipped to SSFL to be decladded and examined.

The hot lab suffered a number of fires involving radioactive materials. For example, in 1957, a fire in the hot cell "got out of control and ... massive contamination" resulted.[27]

At least four of the ten nuclear reactors suffered accidents: 1) The AE6 reactor experienced a release of fission gases in March 1959.[28] 2) In July 1959, the SRE experienced a power excursion and partial meltdown that released 28 Curies of radioactive noble gases. The release resulted in the maximum off-site exposure of 0.099 millirem and an exposure of 0.018 millirem for the nearest residential building which is well within current limits today.[29] 3) In 1964, the SNAP8ER experienced damage to 80% of its fuel. 4) In 1969 the SNAP8DR experienced similar damage to one-third of its fuel.[28]

A radioactive fire occurred in 1971, involving combustible primary reactor coolant (NaK) contaminated with mixed fission products.[30][31]

Sodium burn pits

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Toxic substances burn and are released into the air.

The sodium burn pit, an open-air pit for cleaning sodium-contaminated components, was also contaminated[when?] by the burning of radioactively and chemically contaminated items in it, in contravention of safety requirements. In an article in the Ventura County Star, James Palmer, a former SSFL worker, was interviewed. The article notes that "of the 27 men on Palmer's crew, 22 died of cancers." On some nights Palmer returned home from work and kissed "his wife [hello], only to burn her lips with the chemicals he had breathed at work." The report also noted that "During their breaks, Palmer's crew would fish in one of three ponds ... The men would use a solution that was 90 percent hydrogen peroxide to neutralize the contamination. Sometimes, the water was so polluted it bubbled. The fish died off." Palmer's interview ended with: "They had seven wells up there, water wells, and every damn one of them was contaminated," Palmer said, "It was a horror story."[32]

 
A worker disposes of toxic chemicals by blowing up full barrels with a rifle shot (the reaction to the shot caused an explosion).

In 2002, a Department of Energy (DOE) official described typical waste disposal procedures used by Field Lab employees in the past. Workers would dispose of barrels filled with radioactive sodium by dumping them in a pond and then shooting the barrels with rifles so that they would explode and release their contents into the air.[33] Since then, the pit has been remediated by having 22,000 cubic yards of soil removed down 10–12 feet (3.0–3.7 m) to bedrock.[33]

On 26 July 1994, two scientists, Otto K. Heiney and Larry A. Pugh were killed when the chemicals they were illegally burning in open pits exploded. After a grand jury investigation and FBI raid on the facility, three Rocketdyne officials pleaded guilty in June 2004 to illegally storing explosive materials. The jury deadlocked on the more serious charges related to illegal burning of hazardous waste.[34][35] At trial, a retired Rocketdyne mechanic testified as to what he witnessed at the time of the explosion: "I assumed we were burning waste," Lee Wells testified, comparing the process used on 21 and 26 July 1994, to that once used to legally dispose of leftover chemicals at the company's old burn pit. As Heiney poured the chemicals for what would have been the third burn of the day, the blast occurred, Wells said. "[The background noise] was so loud I didn't hear anything ... I felt the blast and I looked down and my shirt was coming apart." When he realized what had occurred, Wells said, "I felt to see if I was all there ... I knew I was burned but I didn't know how bad." Wells suffered second- and third-degree burns to his face, arms and stomach.[36]

2018 Woolsey fire

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The 2018 Woolsey Fire began at SSFL and burned about 80% of the site.[37] After the fire, the Los Angeles County Department of Public Health found "no discernible level of radiation in the tested area" and the California Department of Toxic Substances Control, which is overseeing cleanup of the site, said in an interim report that "previously handled radioactive and hazardous materials were not affected by the fire."[38] Bob Dodge, President of Physicians for Social Responsibility-Los Angeles, said "When it burns and becomes airborne in smoke and ash, there is real possibility of heightened exposure for area residents."[38]

In 2019, Risk Assessment Corporation (RAC) conducted soil sampling surrounding the SSFL, and performed source term estimation, atmospheric transport, and deposition modeling. The study reports published in 2023, concluded,[39][40]

Air measurement data collected during the Woolsey Fire, along with atmospheric dispersion modeling and an offsite soil sampling program designed specifically to look for impacts from the fire, showed no evidence of SSFL impact in offsite soils because of the Woolsey Fire. No anthropogenic radionuclides were measured at levels above those expected from global fallout. The soil sampling confirmed that no detectable levels of SSFL-derived radionuclides migrated from SSFL at the locations sampled because of the Woolsey Fire or from past operations of the SSFL.

In 2020, the California Department of Toxic Substances Control (DTSC) stated in their final report that the fire did not cause contaminants to be released from the site into Simi Valley and other neighboring communities and that the risk from smoke exposure during the fire was not higher than what is normally associated with wildfire.[41][42]

In 2021 a study which collected 360 samples of dust, ash, and soils from homes and public lands three weeks after the fire found that most samples were at normal levels, ("Data did not support a finding of widespread deposition of radioactive particles.") but that two locations "contained high activities of radioactive isotopes associated with the Santa Susana Field Laboratory."[37][43][44]

Medical claims

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In October 2006, the Santa Susana Field Laboratory Advisory Panel, made up of independent scientists and researchers from around the United States, concluded that based on available data and computer models, contamination at the facility resulted in an estimated 260 cancer related deaths. The report also concluded that the SRE meltdown caused the release of more than 458 times the amount of radioactivity released by the Three Mile Island accident. While the nuclear core of the SRE released 10 times less radiation than the TMI incident, the lack of proper containment such as concrete structures caused this radiation to be released into the surrounding environment. The radiation released by the core of the TMI was largely contained.[45]

According to studies conducted by Hal Morgenstern between 1988 and 2002, residents living within 2 miles (3.2 km) of the laboratory are 60% more likely to be diagnosed with certain cancers compared to residents living 5 miles (8.0 km) from the laboratory, though Morgenstern said that the lab is not necessarily the cause.[4]

Cleanup Standards

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During its years of rocket engine tests and nuclear research and operations, SSFL’s soil became contaminated with chemicals and radionuclides. Several accidents occurred in nuclear facilities, including the 1959 SRE core damage accident (see section on the Sodium Reactor Experiment). In addition, groundwater under SSFL is contaminated (principally with the solvent, TCE) following some 30,000 rocket engine tests. Extensive characterization has been completed for chemicals and radionuclides.[46][47] The majority of SSFL buildings and facilities have been decommissioned and removed, and numerous interim soil cleanups have been conducted.[48][49] DTSC leads site cleanup involving responsible parties (Boeing, DOE, and NASA), agencies (DTSC, LARWQCB, CDPH), and other stakeholders (activist organizations, community members, state and federal legislators, and the media). Cleanup standards and remedial options (remedy selection) continue to be debated and litigated.  DTSC’s Final Program Environmental Impact Report (2023) estimates that soil cleanup will take another 15 years.[50][51] The following summarizes in a generally chronological order, key events related to cleanup standards for both land and building structures and associated remedial options.

1996 DOE and CDHS Approves Boeing’s Radiological Cleanup Standards

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In March 1996, Rockwell proposed radiological cleanup standards for soil and buildings at SSFL.[52] CDHS approved these standards in August 1996.[53] DOE approved these standards in September 1996.[54] Subsequently, Boeing issued final cleanup standards in February 1999.[55] The soil cleanup goal was based on a dose rate of 15 mrem/y above background (300 mrem/y). This was consistent (and less than) NRC’s future 25 mrem/y License Termination Rule[56] and USEPA’s proposed 15 mrem/y dose-based goal for CERCLA remediation sites developed during the late1990s.[57][58][59]

In May 1999, Senator Feinstein sent a series of letters to the Clinton Administration expressing concerns about nuclear decommissioning cleanup standards at SSFL.[60] In June 1999, Boeing documented the basis for cleanup standards in use at SSFL, that were identical to standards used in the rest of the U.S.[61]

2001 CDHS Adopts NRC’s Decommissioning Standards

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In 2001, the California Department of Health Services (CDHS) conducted a public hearing proposing to adopt by reference, the Nuclear Regulatory Commission’s 10 CFR 20 Subpart E, otherwise known as the License Termination Rule, that would codify the federal cleanup standard of 25 mrem/y.[62][63] California, being an Agreement State, was obligated to utilize nuclear regulations, consistent with federal NRC regulations.

2002 CBG Sues CDHS

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In March 2002, the Committee to Bridge the Gap (CBG), the Southern California Federation of Scientists (SCFS) and the Physicians for Social Responsibility - Los Angeles (PSR-LA), sued CDHS,[64] arguing that CDHS cannot adopt 10 CFR 20 Subpart E, and should comply with CEQA and the California APA, conduct an Environmental Impact Report (EIR) and conduct public hearings before adopting safe dose-based decommissioning standards. In April 2002 and June 2002, Judge Ohanesian, concurred with plaintiffs’ complaint.[65][66] As of January 2024, twenty-two years later, CDHS (now CDPH) has ignored the Judge’s Order and still does not have a dose-based decommissioning standard or any numerical criteria for license termination of nuclear or radiological facilities.

2003 DOE Environmental Assessment

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In March 2003, DOE issued an Environmental Assessment (EA)[67] that proposed a radiological cleanup standard of 15 mrem/y, that was safe and protective of public health, consistent with EPA’s one-time, draft dose-base standards[68][69] and more restrictive than the NRC’s 25 mrem/y dose-based standard.[70]

2004 NRDC Sues DOE

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In September 2004, NRDC, CBG and the City of Los Angeles sued DOE claiming that the 2003 EA had violated the National Environmental Policy Act (NEPA), the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) and Endangered Species Act (ESA). The lawsuit claimed that a full Environmental Impact Statement (EIS) should have been performed prior to selecting a soil cleanup remedy.[71] In May 2007, US District Court Judge Samuel Conti found in favor of the plaintiffs stating that DOE had violated NEPA and should prepare a more detailed Environmental Impact Statement (EIS).[72] In November 2018, DOE issued the final EIS,[73] over 11 years after Judge Conti’s Order. As of January 2024, more than five years later, DOE has yet to issue a Record of Decision (ROD) on a soil cleanup standard for radionuclides and chemicals in Area IV.

2007 Technical Feasibility of Detecting Radionuclide Contamination

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In March 2007, Boeing issued a paper, utilizing EPA data,[74] that detection of radionuclides at a 10-6 risk level for an agricultural land use scenario, was technically infeasible.[75] This was prepared in response to initial California Senate hearings on SB 990 that would become California law nine months later (see later).

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In August 2007, DTSC, Boeing, DOE and NASA signed a Consent Order for Corrective Action, outlining planning, risk assessments and schedules for remediation at SSFL.[76]  The Consent Order was focused exclusively on chemical remediation of soil and groundwater. It was silent on radiological remediation and nuclear decommissioning. The Consent Order established a timeline for site cleanup to be completed by 2017.[77]

2007 Radiological Release Process

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In September 2007, Boeing issued “Radiological Release Process - Process for the Release of Land and Facilities for (Radiologically) Unrestricted Use” which described the key steps in a generic decommissioning process typical of that used elsewhere in the United States.[78]

2007 SB 990

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In October 2007, SB 990 (Kuehl) was passed in the California Senate, that mandated an agricultural risk-based cleanup standard for chemicals and radionuclides and transferred regulatory authority for radiological cleanup at SSFL from CDHS and DOE to DTSC.[79] SB 990 became law on January 1, 2008.

In October 2007, Boeing and Governor Schwarzenegger announced the intent to transfer SSFL to the State of California as open space parkland (following completion of remediation),[80][81] along with an agreement from State Senator Sheila Kuehl that she would amend SB 990 to withdraw requirements for agricultural land use and DTSC land transfer approval.[82][83]

In January 2008, this agreement fell through, following objections by other parties (CBG, NRDC, Sierra Club, PSR-LA, SCFS, etc).[84] These parties also objected to NPL listing by EPA since it would have taken control of cleanup out of the hands of DTSC (who would require cleanup-to-background in the future 2010 AOC) and given it to EPA (who would implement a CERCLA risk-based cleanup).

Boeing remained committed to the future of SSFL as open space, as evidenced by the April 2017 conservation easement recorded with the North American Land Trust (NALT) to permanently preserve and protect Boeing’s 2,400 acres at the Santa Susana site.[85]

In November 2009, Boeing sued DTSC over SB 990,[86] following months of unsuccessful negotiations between DTSC, Boeing, DOE and NASA attempting to incorporate the requirements of SB 990 into the 2007 Consent Order.

In April 2011, Judge John Walter of the United States District Court (Central District of California) issued an order[87][88] in favor of Boeing, stating, “SB 990 is declared invalid and unconstitutional in its entirety under the Supremacy Clause of the United States Constitution” and “DTSC is hereby enjoined from enforcing or implementing SB 990.” In September 2014, the United States Court of Appeals (Ninth Circuit) upheld and affirmed the lower Court’s judgement.[89]

2010 AOCs

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Perhaps in anticipation of losing the SB 990 lawsuit to Boeing, in December 2010, DTSC “encouraged” DOE and NASA to sign two identical Administrative Orders on Consent (AOCs)[90][91] in which both RPs agreed to (1) clean-up to background, (2) dispense with EPA’s CERCLA risk assessment guidelines, (3) define soil to include building structures, and (4) send all soil (and structures) that exceed background radionuclides to an out-of-state licensed low-level radioactive waste disposal facility. Boeing had refused to negotiate or sign its own AOC, being involved in litigation with the State, over SB 990.

2010-2013 Boeing Building Demolition

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Between 2010 and 2013, Boeing demolished 40 remaining Boeing-owned non-radiological buildings in Areas I, III and IV based on DTSC approved procedures.[92] Subsequent proposals in 2013 to demolish 6 remaining, released-for-unrestrictive-use, former radiological buildings in Area IV met with resistance.  In August 2013, the Physicians for Social Responsibility - Los Angeles (PSR-LA) plus others, sued the DTSC, CDPH and Boeing, alleging that demolition debris from these buildings was LLRW and should be disposed out-of-state to a licensed low-level radioactive waste disposal facility.[93] Five years later, in November 2018, the Superior Court of California found for the defendants.[94] Five years later, in May 2023, the California Appeals Court reaffirmed the lower Court’s decision, denying plaintiffs’ petition.[95] Subsequently Plaintiffs petitioned the California Supreme Court to review the case. The California Supreme Court denied the petition for review.

2020 DOE Building Demolition

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In May 2020, DTSC and DOE signed an Order on Consent for Interim Response Action at the Radioactive Material Handling Facility (RMHF) Complex.[96] The Order on Consent required all demolition debris to be disposed out of the State of California at a licensed LLRW or MLLRW disposal facility or a DOE authorized LLRW or MLLRW disposal facility.

In October 2020, DTSC and DOE signed an Amendment to Order on Consent for Interim Response Action at the Radioactive Materials Handling Facility (RMHF) Complex.[97] The title was misleading since the agreement has nothing to do with the RMHF, but states requirements for the demolition and disposal of eight remaining DOE-owned, non-RMHF facilities. These eight buildings included two that had been surveyed, confirming that structures to be demolished met all federal and state cleanup standards; two buildings that had been decommissioned and released for unrestricted use by DOE; and four buildings that had no history of radiological use, but had nevertheless been surveyed and confirmed to be “indistinguishable from background.” Nevertheless, “out of an abundance of caution,” the Amendment caused all demolition debris from all eight buildings, to be disposed of, out of the State of California, to a licensed MLLRW disposal facility.

NASA Building Demolition

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NASA, in contrast to Boeing and DOE, appeared to have escaped the attention of DTSC and their partners, and was not required to dispose of building debris to a licensed LLRW disposal facility, “out of an abundance of caution.”

2018 DOE Environmental Impact Statement (EIS)

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In January 2017, DOE issued its Draft SSFL Area IV Environmental Impact Statement.[98] In November 2018, DOE issued its Final Environmental Impact Statement, eleven years after it was ordered by Judge Conti in 2007.[99] DOE’s preferred alternative for remediation of soils is the Conservation of Natural Resources, Open Space Scenario. DOE identified this preferred alternative because it would be consistent with the risk assessment approach typically used at other DOE sites, other California Department of Toxic Substances Control (DTSC) regulated sites, and U.S. Environmental Protection Agency CERCLA sites, which accounts for the specific open-space recreational future land use of the site. Use of a risk assessment approach would be consistent with the Grant Deeds of Conservation Easement and Agreements that commit Boeing’s SSFL property, including Area IV and the NBZ, to remaining as open space. This scenario would use a CERCLA risk assessment approach that would be protective of human health and the environment. This does not comply with the DTSC 2010 AOC “cleanup to background” mandate. DOE and DTSC have yet to negotiate a Record of Decision (ROD) for soils.

2014-2020 NASA Environmental Impact Statement (EIS)

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In March 2014, NASA issued its Final Environmental Impact Statement for Proposed Demolition and Environmental Cleanup Activities at Santa Susana Field Laboratory.[100] In July 2020, NASA issued its Final Supplemental EIS for Soil Cleanup Activities.[101] In September 2020, NASA issued its Record of Decision (ROD) for its Supplemental EIS for soil cleanup.[102] The ROD identified Alternative C, Suburban Residential Cleanup as the Agency-Preferred Alternative. This does not comply with the DTSC 2010 AOC “cleanup to background” mandate. NASA recognizes the need to take no action until DTSC issues its ROD based on its Program Environmental Impact Report (PEIR).

2017-2023 DTSC Program Environmental Impact Report (PEIR)

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In September 2017, DTSC issued its Draft Program Environmental Impact Report for the Santa Susana Field Laboratory.[103] In June 2023, following community input, DTSC issued its Final Program Environmental Impact Report for the Santa Susana Field Laboratory.[104] DTSC stated that the PEIR was not a decision document (i.e. ROD), but nevertheless made it clear that it still supports the 2010 AOC requirements to cleanup radionuclides and chemicals to background, that is in conflict with DOE’s and NASA’s preferred alternatives in their respective Final EISs. Curiously, DTSC also issued in June 2023, a revised version of its draft PEIR, with deletions and additions.[105] It was not immediately obvious why this was necessary in addition to the Final PEIS.

2022 DTSC-Boeing Settlement Agreement

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In May 2022, DTSC and Boeing signed a Settlement Agreement (SA) including a commitment by Boeing to cleanup chemicals to a residential risk-based garden standard (100% consumption of garden-grown fruits and vegetables) and cleanup radionuclides to background, in its areas of responsibility, namely Area I and III and the southern buffer zone.[106] The Settlement Agreement was criticized by community groups and local governments for being done in secret, without public input; they also allege that it weakened the cleanup standards.[107]

2023 Surface Water

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Although separately, Boeing, DOE and NASA are responsible for remediation of soil and groundwater in Areas I/III, Area IV, and Area II respectively, Boeing alone is responsible for management and treatment of surface water (i.e. storm water) for the entire SSFL site. The SSFL National Pollution Discharge Elimination System (NPDES) Permit regulates discharge of surface water when, and if, it flows offsite. Radionuclide limits are identical to the EPA’s drinking water supplier limits. These are the same limits that regulate the water in our faucets, Chemical NPDES limits are, in general, even lower than EPA’s drinking water supplier limits, and are often based on ecological risk limits. The NPDES Permit has been in existence for decades. The current Permit was issued in October 2023.[108]

In August 2022, a Memorandum of Understanding (MOU) was signed between Boeing and LARWQCB that describes future storm water management requirements following completion of SSFL soil remediation.[109]

Community Involvement

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Community Advisory Group

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A petition to form a "CAG" or community advisory group was denied in March 2010 by DTSC.[110][111] In 2012, the current CAG's petition was approved. The SSFL CAG recommends that all responsible parties execute a risk-based cleanup to EPA's suburban residential standard that will minimize excavation, soil removal and backfill and thus reduce danger to public health and functions of surrounding communities. However, SSFL Panel believes the CAG has a conflict of interest, as it is funded in large part by a grant from the U.S. Department of Energy, and three of its members are former employees of Boeing or its parent company, North American Aviation.[112] It is believed that the SSFL CAG is no longer active.

Documentary

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In 2021, the three hour documentary In the Dark of the Valley depicted mothers advocating for cleanup of the site who have children suffering from cancer believed to be caused by the contamination.[113]

See also

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References

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  1. ^ a b Archeological Consultants, Inc.; Weitz Research (March 2009). "Historical resources survey and assessment of the NASA facility at the Santa Susana Field Laboratory, Simi Valley, California" (PDF). NASA. p. 1. Archived from the original (PDF) on 27 June 2011. Retrieved 25 January 2010.
  2. ^ "Sage.Park".
  3. ^ Sapere and Boeing (May 2005). Santa Susana Field Laboratory, Area IV Historical Site Assessment. p. 2. Archived from the original on 12 December 2009. Retrieved 25 January 2010.
  4. ^ a b Simon, Melissa (13 April 2018). "Protestors want SSFL cleaned up | Simi Valley Acorn". www.simivalleyacorn.com. Simi Valley Acorn. Retrieved 18 April 2018. But there is no definitive proof that the contamination left from decades of nuclear testing is the source of cancers and other health issues. ... Hal Morgenstern, an epidemiology professor at the University of Michigan, conducted several studies between 1988 and 2002 to see if there was a link between chemical or radioactive contamination at the field lab and deaths caused by leukemia, lymphoma and other cancers. Results showed people living within a 2-mile radius were at least 60 percent more likely to be diagnosed with certain cancers than those living 5 miles away, but that doesn't mean the site's contamination is the cause, Morgenstern previously told the Simi Valley Acorn. Despite the data he collected, Morgenstern said, there wasn't enough evidence to identify an explicit link between cancer and field lab contamination. And the results were inconclusive as to whether activities at SSFL specifically affected or will affect cancer incidences, he said.
  5. ^ "Boeing: Environment - Santa Susana - History". Archived from the original on 26 February 2011.
  6. ^ American Institute of Aeronautics and Astronautics (2001). "Historic Aerospace Site: The Rocketdyne Santa Susana Field Laboratory, Canoga Park, California" (PDF). AIAA. Retrieved 25 January 2010.
  7. ^ DuTemple, Octave. "American Nuclear Society Sodium Reactor Experiment Nuclear Historic Landmark awarded, February 21, 1986" (PDF). Archived from the original (PDF) on 21 July 2011. Retrieved 25 January 2010.
  8. ^ Stokely, C. & Stansbury, E. (2008), "Identification of a debris cloud from the nuclear powered SNAPSHOT satellite with Haystack radar measurements", Advances in Space Research, vol. 41, no. 7, pp. 1004–1009, Bibcode:2008AdSpR..41.1004S, doi:10.1016/j.asr.2007.03.046, hdl:2060/20060028182
  9. ^ Rutherford, Phil (9 June 2022). "Nuclear Decommissioning at the Santa Susana Field Laboratory" (PDF). Phil Rutherford Consulting. Retrieved 12 November 2023.
  10. ^ Rutherford, Phil (2 December 2022). "Offsite Impact of the Santa Susana Field Laboratory" (PDF). Phil Rutherford Consulting. Retrieved 12 November 2023.
  11. ^ Chiotakis, Steve (15 October 2020). "Cancer, contamination, and cave paintings: Santa Susana cleanup gets more complicated". KCRW. Retrieved 17 October 2020.
  12. ^ "SSFL Surface Water Map".
  13. ^ "Site Safety and Health Plan Area IV Radiological Study Santa Susana Field Laboratory Ventura County, California" (PDF). U.S. Environmental Protection Agency. Retrieved 28 September 2016.
  14. ^ a b "A Look Back at Space Mission Engine Testing at the Santa Susana Field Laboratory" (PDF).
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  27. ^ NAA-SR-1941, Sodium Graphite Reactor, Quarterly Progress Report, January–March 1957, p. 27
  28. ^ a b "Report of the Santa Susana Field Laboratory Advisory Panel" (PDF). October 2006. Retrieved 30 September 2010.
  29. ^ "Accident report" (PDF). www.etec.energy.gov.
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  32. ^ ”The Cancer Effect”, 30 October 2006, Ventura County Star
  33. ^ a b Collins, Michael (19 February 2003). "Rocketdyne: It's the pits - Lots of questions, few answers at the latest meeting on Rocketdyne cleanup". Ventura County Reporter. Archived from the original on 19 February 2003. Lopez described the cleanup of the heavily polluted sodium burn pit, a six-acre site where Rocketdyne disposed of massive amounts of radioactive waste. The modus operandi included chucking barrels of radioactive sodium into the sludgy pond and firing a gun at the canisters, which would then explode, releasing radioactive contaminants into the air. Lopez said that the pit has now been excavated ten to 12 feet down to the bedrock, resulting in the removal of 22,000 cubic yards of soil.
  34. ^ Guccione, Jean (11 December 2003). "Scientist Fined $100 in Lab Blast That Killed 2". Los Angeles Times.
  35. ^ Guccione, Jean (28 January 2003). "Executive Sentenced in '94 Blast". Los Angeles Times.
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  37. ^ a b Harris, Mike (17 October 2021). "Study finds radioactive contamination migrated off field lab site during Woolsey Fire". Ventura County Star. Retrieved 17 October 2021. The Woolsey Fire broke out at the site on Nov. 8, 2018, sparked during high winds by electrical equipment owned there by Southern California Edison, an investigation by the Ventura County Fire Department concluded. The blaze went on to burn about 97,000 acres, including 80% of the field lab site, ... The study examined 360 samples of household dust, surface soils and ash from 150 homes and other locations such as parks and trails collected after the fire. It concluded that while most of the collected samples were at normal levels, "some ashes and dusts collected from the Woolsey Fire zone in the fire's immediate aftermath contained high activities of radioactive isotopes associated with the Santa Susana Field Laboratory."
  38. ^ a b Ortiz, Erik (14 November 2018). "Activists concerned after wildfire ripped through nuclear research site". NBC News. Archived from the original on 14 November 2018. Retrieved 14 November 2018.
  39. ^ Risk Assessment Corporation (April 2023). "Potential Airborne Releases and Deposition of Radionuclides from the Santa Susana Field Laboratory during the Woolsey Fire". Health Physics. 124 (4): 257–284. doi:10.1097/HP.0000000000001665. PMC 9940825. PMID 36749301. Retrieved 16 July 2023.
  40. ^ Risk Assessment Corporation (26 October 2020). "Evaluation of Off-site Impacts from the Woolsey Fire Burning on Portions of the Santa Susana Field Laboratory Site" (PDF). Retrieved 16 July 2023.
  41. ^ "DTSC Final Summary Report of Woolsey Fire" (PDF). California Department of Toxic Substances Control. 1 December 2020. Retrieved 28 October 2021.
  42. ^ Harris, Mike (19 January 2021). "State reaffirms Woolsey Fire didn't cause toxins to be released from field lab site". Ventura County Star. Retrieved 20 January 2021.
  43. ^ Kaltofen, Marco; Gundersen, Maggie; Gundersen, Arnie (1 December 2021). "Radioactive microparticles related to the Woolsey Fire in Simi Valley, CA". Journal of Environmental Radioactivity. 240: 106755. Bibcode:2021JEnvR.24006755K. doi:10.1016/j.jenvrad.2021.106755. PMID 34634531. S2CID 238637473. In two geographically-separated locations, one as far away as 15 km, radioactive microparticles containing percent-concentrations of thorium were detected in ashes and dusts that were likely related to deposition from the Woolsey fire. These offsite radioactive microparticles were colocated with alpha and beta activity maxima. Data did not support a finding of widespread deposition of radioactive particles. However, two radioactive deposition hotspots and significant offsite contamination were detected near the site perimeter.
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  51. ^ DTSC (July 2023). "SSFL PEIR Community Update" (PDF). DTSC SSFL Website. Retrieved 28 January 2024.
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  59. ^ USEPA (11 May 1999). "Draft Environmental Protection Agency Radiation Site Cleanup Regulation - Notice of Proposed Rulemaking" (PDF). Phil Rutherford Consulting. Retrieved 28 January 2024.
  60. ^ Polakovic, Gary (8 May 1999). "Senator Seeks Tougher Cleanup Standards at Rocketdyne Lab". Los Angeles Times. Retrieved 28 January 2024.
  61. ^ Boeing (10 June 1999). "Radiation Cleanup Standards - A Position Paper" (PDF). DTSC SSFL Website. Retrieved 28 January 2024.
  62. ^ USNRC. "Radiological Criteria for Unrestricted Use. 10 CFR 20.1402 Subpart E." USNRC Website. Retrieved 28 January 2024.
  63. ^ CDHS/RHB (1 May 2000). "Radiological Release Criteria for Facilities Undergoing Large-Scale Decommissioning. RML-00-02" (PDF). Phil Rutherford Consulting. Retrieved 28 January 2024.
  64. ^ Superior Court of California. Sacramento County. Case 01CS01445. 29 March 2002
  65. ^ Superior Court of California (10 April 2002). "Superior Court of California, Sacramento County. Case 01CS01445. Ruling on Submitted Matter" (PDF). Phil Rutherford Consulting. Retrieved 28 January 2024.
  66. ^ Superior Court of California (19 June 2002). "Superior Court of California, Sacramento County. Case 01CS01445. Amended Peremptory Writ of Mandate" (PDF). Phil Rutherford Consulting. Retrieved 28 January 2024.
  67. ^ USDOE (March 2003). "Environmental Assessment for Cleanup and Closure of the Energy Technology Engineering Center. DOE/EA-1345" (PDF). DOE ETEC Website. Retrieved 28 January 2024.
  68. ^ USEPA (11 May 1999). "Draft Environmental Protection Agency Radiation Site Cleanup Regulation. Draft 40 CFR 196" (PDF). Phil Rutherford Consulting. Retrieved 28 January 2024.
  69. ^ USEPA (22 August 1997). "Establishment of Cleanup Levels for CERCLA Sites with Radioactive Contamination. OSWER 9200.4-18" (PDF). USEPA Website. Retrieved 28 January 2024.
  70. ^ USNRC. "Radiological Criteria for License Termination", 10 CFR 20.1402 Subpart E". USNRC Website. Retrieved 28 January 2024.
  71. ^ Meyer & Glitzenstein (19 July 2004). "Cleanup of the Santa Susana Field Laboratory in Simi Valley" (PDF). Phil Rutherford Consulting. Retrieved 28 January 2024.
  72. ^ US District Court (2 May 2007). "US District Court, Northern District of California. Case No. C-04-04448 SC. Order Granting Plaintiffs' Motion for Summary Judgement" (PDF). DOE ETEC Website. Retrieved 28 January 2024.
  73. ^ USDOE (November 2018). "Final Environmental Impact Statement for Remediation of Area IV and the Northern Buffer Zone of the Santa Susana Field Laboratory. DOE/EIS-0402". USDOE Website. Retrieved 28 January 2024.
  74. ^ USEPA (September 1994). "Radiation Site Cleanup Regulations: Technical Support Document for the Development of Radionuclide Cleanup Levels for Soil, EPA 402-R-96-011 A" (PDF). USEPA Website. Retrieved 28 January 2024.
  75. ^ Boeing (6 March 2007). "Technical Feasibility of Detecting Radionuclide Contamination in Soil at a 10-6 Risk Level for Agricultural Land Use" (PDF). DOE ETEC Website. Retrieved 28 January 2024.
  76. ^ DTSC (16 August 2007). "Consent Order for Corrective Action" (PDF). DTSC SSFL Website. Retrieved 28 January 2024.
  77. ^ DTSC (16 August 2007). "Consent Order for Corrective Action" (PDF). DTSC SSFL Website. Retrieved 28 January 2024. p. 10.
  78. ^ Boeing/Rutherford (17 September 2007). "Radiological Release Process - Process for the Release of Land and Facilities for (Radiologically) Unrestricted Use" (PDF). DOE ETEC Website. Retrieved 28 January 2024.
  79. ^ California Senate (Kuehl) (14 October 2007). "SB 990 (Kuehl). Hazardous Waste: Santa Susana Field Laboratory". California Legislative Website. Retrieved 28 January 2024.
  80. ^ Boeing (12 October 2007). "Boeing Press Release. Boeing Commits Historic Santa Susana Site to Open Space" (PDF). Phil Rutherford Consulting. Retrieved 28 January 2024.
  81. ^ Governor Schwarzenegger (12 October 2007). "Press Release. Gov. Schwarzenegger to Sign Measure to Accelerate Cleanup Santa Susana Field Laboratory in Ventura County" (PDF). Phil Rutherford Consulting. Retrieved 28 January 2024.
  82. ^ Kuehl, Sheila (12 October 2007). "SB 990 (Kuehl): Cleanup of Santa Susana Field Laboratory Property" (PDF). Phil Rutherford Consulting. Retrieved 28 January 2007.
  83. ^ Proposed Amended Language to SB 990. Online citation needed. 12 October 2007
  84. ^ Sierra Club (15 January 2008). "Letter to Linda Adams, Secretary CalEPA. Letter of Intent Regarding Remediation of the Santa Susana Field Laboratory Property" (PDF). DTSC SSFL Website. Retrieved 28 January 2024.
  85. ^ Boeing (24 April 2017). "Conservation Easement - Santa Susana" (PDF). Boeing Website. Retrieved 28 January 2024.
  86. ^ United States District Court (13 November 2009). "United States District Court, Eastern District of California. Complaint of the Boeing Company" (PDF). DTSC SSFL Website. Retrieved 28 January 2024.
  87. ^ US District Court (26 April 2011). "US District Court (Central District of California). Order Granting Plaintiff The Boeing Company's Motion for Summary Judgement. Case CV 10-4839-JFW (MANx)" (PDF). DTSC SSFL Website. Retrieved 28 January 2024.
  88. ^ US District Court (5 May 2011). "US District Court (Central District of California). Judgement Pursuant to Fed. R Civ. P. 54(b). Case CV 10-04839-JFW (MANx)" (PDF). DTSC SSFL Website. Retrieved 28 January 2024.
  89. ^ US Court of Appeals (19 September 2014). "US Court of Appeals (Ninth Circuit). Opinion. No. 11-55903. D.C. No. 2:10-cv-04839-JFW-MAN" (PDF). DTSC SSFL Website. Retrieved 28 January 2024.
  90. ^ DTSC and DOE (6 December 2010). "Administrative Order on Consent for Remedial Action, 2010 DOE AOC" (PDF). DTSC SSFL Website. Retrieved 28 January 2024.
  91. ^ DTSC and NASA (6 December 2010). "Administrative Order on Consent for Remedial Action, 2010 NASA AOC" (PDF). DTSC SSFL Website. Retrieved 28 January 2024.
  92. ^ Boeing (19 April 2013). "Standard Operating Procedure: Building Demolition Debris Characterization and Management. Plus Amendments 1 and 2" (PDF). DTSC SSFL Website. Retrieved 28 January 2024.
  93. ^ PSR-LA (6 August 2013). "Superior Court of California. County of Sacramento. Verified Petition for Writ of Mandate and Complaint for Injunctive and Declaratory Relief. Case 34-2013-80001589" (PDF). Phil Rutherford Consulting. Retrieved 28 January 2024.
  94. ^ California Superior Court (19 November 2019). "California Superior Court. Ruling on Submitted Matter Re: Petition for Writ of Mandate and Complaint for Injunctive and Declaratory Relief" (PDF). DTSC SSFL Website. Retrieved 28 January 2024.
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  97. ^ DTSC (20 October 2020). "Amendment to Order on Consent for Interim Response Action at the Radioactive Materials Handling Facility (RMHF) Complex" (PDF). DTSC SSFL Website. Retrieved 28 January 2024.
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  99. ^ USDOE (November 2018). "Final SSFL Area IV EIS Document". DOE Website. Retrieved 28 January 2024.
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  102. ^ NASA (September 2020). "Record of Decision - Supplemental Environmental Impact Statement for Soil Cleanup Activities at Santa Susana Field Laboratory, Ventura County, California" (PDF). NASA Website. Retrieved 28 January 2024.
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  104. ^ DTSC (June 2023). "Final Program Environmental Impact Report for the Santa Susana Field Laboratory" (PDF). DTSC SSFL Website. Retrieved 28 January 2024.
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  107. ^ Grigoryants, Olga (12 May 2022). "State's new deal to clean up radioactive Santa Susana Field Lab is slammed by critics". Los Angeles Daily News. Archived from the original on 13 April 2024. Retrieved 19 August 2024.
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  109. ^ LARWQCB (12 August 2022). "Memorandum of Understanding Establishing the Processes, Methodologies, and Standards for Assessing Stormwater Discharges and Applicable Requirements following The Boeing Company Soil Cleanup at the Santa Susana Field Laboratory Site" (PDF). LARWQCB Website. Retrieved 28 January 2024.
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  112. ^ "Dept. of Energy secretly funding front group to sabotage its own Santa Susana Field Lab cleanup". 1 September 2016.
  113. ^ Mihm, Nicholas (director) (14 November 2021). In the Dark of the Valley (Motion picture). Los Angeles, CA.
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Wikimedia Commons has media related to Santa Susana Field Laboratory.
External videos
  Fly-through Animation of Test Stand 1, Santa Susana Field Laboratory Area II, California, HAER, 27 March 2013
  Fly-through Animation of Bravo Test Area at the Santa Susana Field Laboratory, Santa Susana, CA, HAER, 25 September 2013
  Fly-through of Coca Test Area at Santa Susana Field Laboratory, HAER 6 June 2013

Responsible parties and agencies

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Groups

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Media

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Reactor accident sources

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  • "-NAA-SR-MEMO-3757" (PDF). Archived from the original (PDF) on 28 September 2007. Retrieved 5 March 2007. Release of Fission Gas from the AE-6 Reactor, hosted by RocketdyneWatch.org
  • "-NAA-SR-5898" (PDF). Archived from the original (PDF) on 28 September 2007. Retrieved 5 March 2007. Analysis of SRE Power Excursion, hosted by RocketdyneWatch.org
  • "-NAA-SR-4488" (PDF). Archived from the original (PDF) on 28 September 2007. Retrieved 14 March 2007. SRE Fuel Element Damage an Interim Report, hosted by RocketdyneWatch.org
  • "-NAA-SR-4488-Suppl" (PDF). Archived from the original (PDF) on 28 September 2007. Retrieved 14 March 2007. SRE Fuel Element Damage Final Report, hosted by RocketdyneWatch.org
  • "-NAA-SR-MEMO-12210" (PDF). Archived from the original (PDF) on 28 September 2007. Retrieved 14 March 2007. SNAP8 Experimental Reactor Fuel Element Behavior: Atomics International Task Force Review, hosted by RocketdyneWatch.org
  • "-NAA-SR-12029" (PDF). Archived from the original (PDF) on 28 September 2007. Retrieved 14 March 2007. Postoperation Evaluation of Fuel Elements from the SNAP8 Experimental Reactor hosted by RocketdyneWatch.org
  • "-AI-AEC-13003" (PDF). Archived from the original (PDF) on 28 September 2007. Retrieved 19 March 2007. Findings of the SNAP 8 Developmental Reactor (S8DR) Post-Test Examination, hosted by RocketdyneWatch.org

34°13′51″N 118°41′47″W / 34.230822°N 118.696375°W / 34.230822; -118.696375

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